Clinton v. Goldsmith
1999 U.S. LEXIS 3173, 143 L. Ed. 2d 720, 526 U.S. 529 (1999)
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Rule of Law:
The All Writs Act does not grant an appellate court, such as the Court of Appeals for the Armed Forces (CAAF), jurisdiction to review an executive action that is not part of a court-martial finding or sentence. The Act can only be used to issue writs "in aid of" a court's existing, statutorily defined jurisdiction and is not available when other adequate legal remedies exist.
Facts:
- James Goldsmith, a major in the U.S. Air Force who was HIV-positive, was ordered by a superior officer to inform his sex partners of his status and to use protective measures.
- On two occasions, Goldsmith had unprotected intercourse with partners without disclosing his HIV status, in direct violation of the order.
- As a result, Goldsmith was convicted by a general court-martial for willful disobedience of an order and assault.
- In 1994, the court-martial sentenced Goldsmith to six years' confinement and forfeiture of pay, but it did not sentence him to be dismissed from the Air Force.
- In 1996, Congress passed a statute authorizing the President to drop from the rolls any officer who had been sentenced by court-martial to more than six months' confinement and had served at least six months.
- Relying on this new statute, the Air Force notified Goldsmith in 1996 that it was initiating action to drop him from the rolls.
Procedural Posture:
- Goldsmith was convicted and sentenced by a general court-martial in 1994.
- The Air Force Court of Criminal Appeals, an intermediate military appellate court, affirmed the conviction and sentence in 1995.
- Goldsmith did not seek further review, and his court-martial conviction became final.
- After being notified of the action to drop him from the rolls, Goldsmith petitioned the Air Force Court of Criminal Appeals for extraordinary relief for an unrelated matter, which was denied.
- Goldsmith, the appellee, appealed that denial to the U.S. Court of Appeals for the Armed Forces (CAAF), the highest military court, where he first raised his constitutional challenge to being dropped from the rolls.
- The CAAF granted Goldsmith's petition for extraordinary relief and issued an injunction to prevent the President and military officials, the appellants, from dropping him from the rolls.
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Issue:
Does the All Writs Act grant the Court of Appeals for the Armed Forces jurisdiction to enjoin an executive action to remove a service member from the rolls when that action is separate from a finalized court-martial conviction and sentence?
Opinions:
Majority - Justice Souter
No. The All Writs Act does not grant the Court of Appeals for the Armed Forces (CAAF) jurisdiction to enjoin the executive action. The CAAF's statutory jurisdiction is strictly confined to reviewing the findings and sentences of courts-martial. The Air Force's action to drop Goldsmith from the rolls was a separate, executive action, not a finding or sentence imposed by the court-martial. The All Writs Act allows courts to issue writs only "in aid of" their existing jurisdiction; it does not grant them new jurisdictional powers. Since the executive action fell outside the CAAF's statutory authority, the court could not use the Act to interfere with it. Furthermore, the writ was not "necessary or appropriate" because Goldsmith had other adequate remedies at law, including seeking review from the Air Force Board for Correction of Military Records or filing suit in federal district court.
Analysis:
This decision reinforces the principle that specialized federal courts, like the CAAF, are courts of limited jurisdiction strictly defined by Congress. It clarifies that the All Writs Act serves as a tool to effectuate a court's existing authority, not as an independent basis to expand judicial power into the realm of executive administrative actions. The ruling establishes that even when an administrative action is connected to a prior criminal conviction, challenges to that action must proceed through appropriate administrative or Article III judicial channels, rather than through the military's appellate criminal court system. This preserves the separation between the judicial function of reviewing court-martial sentences and the executive function of military administration.
